United States v. Rihanna Buddi -Eastern District of Tennessee at Greeneville
Split Score
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Case Summary
Disposition
Reversed in Part
The Sixth Circuit held that Florida’s lewd and lascivious battery is not comparable to federal coercion-and-enticement under SORNA because § 2422(b) requires proof the defendant knew the victim was a minor. Accordingly, the court re-classified Buddi as a Tier I offender, vacated her 20-year term of supervised release as procedurally unreasonable, and remanded for resentencing.
Circuit Split Identified
Legal Issue
Whether 18 U.S.C. § 2422(b) requires the Government to prove that the defendant knew the victim was a minor.
Circuit Positions
§ 2422(b) requires the defendant to know the victim is a minor.
§ 2422(b) does not require knowledge of the victim’s minor status (strict-liability age element).
Conflict Summary
The Ninth, Seventh, and now Sixth Circuits read the adverb "knowingly" in § 2422(b) to apply to the victim’s age element, requiring proof that the defendant knew the person was under 18. The Eleventh and Fourth Circuits hold that the statute imposes strict liability as to age, requiring no such knowledge.